Concept 2 Keys Development Application Review Program

10th floor, West Tower, City Hall
100 Queen Street West
Toronto, ON M5H 2N2

Attention: Nancy Martins

RE: PH24.4 Concept 2 Keys Development Application Review Program – Second Quarter of 2021 Update 

Dear Ana Bailão, Chair and Members, Planning and Housing Committee,

The Federation of North Toronto Residents Associations represents over 30 residents’ associations in Midtown, North Toronto, and North York.

This report brings forward updates on the work completed to date by the Concept 2 Keys team, highlighting preliminary results of Phase 1, updates on preparatory work for Phase 2, and additional City-wide development process improvements.

The Concept 2 Keys (C2K) program focusses on reducing costs, and increasing efficiency. This is laudable, except that for a government service this singular focus is fundamentally flawed – you are the City and you exist to serve the public, not just customers, i.e. development applicants. Nowhere is there any mention of residents, neighbours, or interests other than that of the applicant or undefined stakeholders.

The report states that the Concept 2 Keys (C2K) program

  • is transforming, enhancing and improving how the City delivers effective and coordinated development review services. The objective is to design and build a development review process that is consistent, transparent, collaborative and accountable across City staff and applicants.

And that

  • C2K has worked at an accelerated pace to implement development review improvements
  • …the C2K program applies an iterative and customer-centric approach to transformation. This involves implementing improvements to the development review process that are service-oriented, accountable, predictable, transparent, performance-based and collaborative.

It would appear that the program objectives are everything that a bottom-line focused private sector manager would require from a management consultant:

  • Improving the overall customer experience for applicants engaging in the development review process;
  • Creating greater accountability and ownership for the end-to-end process across the City;
  • Shifting the culture towards open collaboration and rigorous project management among City staff and applicants;
  • Increasing the efficiency and effectiveness of identification, escalation and resolution of issues within development applications;
  • Increasing the predictability and consistency of the development review process across geographies and commenting partners across the City and among external partners;
  • Focusing staff capacity and expertise on value-add work;
  • Establishing meaningful reductions in application circulations and/or processing times;
  • Enabling real-time data and analytics to manage the application pipeline and drive service planning; and,
  • Improving the completeness and quality of applications submitted by applicants.

The vital element that is missing from the report is how the C2K process takes into account the concerns and interests of the public, and not just the applicant or undefined stakeholders.

We previously raised similar concerns[1] specifically in regard to an earlier report on the virtual Committee of Adjustment process which focused on application productivity metrics and failed to discuss the rampant rubberstamping of applications, the failure to take account of resident concerns, and generally the lack of transparency, and effective public participation.

We request that you reconsider the C2K process to ensure that resident concerns are properly taken into account.

Yours truly,

Geoff Kettel
Co-Chair, FoNTRA

Cathie Macdonald
Co-Chair, FoNTRA

cc: Gregg Lintern Chief Planner and Executive Director, City Planning Division
Matt Keliher Chief Operating Officer, Concept 2 Keys (C2K)


[1] (April 21, 2021) Letter from Geoff Kettel and Cathie Macdonald, Co-Chairs, Federation of North Toronto Residents’ Association (PH.New)